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September 28, 2026

Texas Finalizes Topical Analgesic Plan-Based Audit Plan

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The Texas Division of Workers’ Compensation announced that they have finalized their topical analgesic plan-based audit plan. The plan was finalized after receiving input from workers’ comp stakeholders, following months of meetings, comments, and discussions.

According to the finalized plan, the purpose of the audit will be to ensure that topical analgesics are prescribed in accordance with ODG and evidence-based medical practices. Additionally, the audit will assess provider documentation supporting medical necessity for treatment that deviates from established evidence-based guidelines.

The audit will incorporate an approved Medical Quality Review Process, which determines if prescriptions were:

  • Medically necessary and reasonable
  • Compliant with ODG or other evidence-based medicine
  • Properly documented in medical records
  • Associated with functional improvement or clinical need

The audit will review topical analgesics prescribed between December 1, 2024, and November 30, 2025. Up to 25 health care practitioners will be selected based on prescription volumes. For each selected health care practitioner, up to five cases will be randomly chosen for review.

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